The Final Rule for Modified Meaningful Use was announced by CMS on October 6, 2015. To help practices get a better understanding of the new requirements, necessary to qualify for the upcoming Meaningful Use attestation period, CureMD recently conducted the following webinar: “Meaningful Use in 2015: 6 things to do before the year’s end.”

In case you missed it, here’s a quick recap.

The goal for the new changes made to Meaningful Use by CMS is to reduce the complexity of the EHR Incentive Program, and to focus more on interoperability. This Final Rule addresses the many challenges physicians faced while trying to meet the requirements of Meaningful Use Stage 2. Here is how the Modified Meaningful Use Stage 2 is different from the previous stages:

The updated Final Rule by CMS requires practices to meet 10 objectives, with one or more measures, in order to qualify for ‘Modified’ Meaningful Use. These measures in each objective are as follows:

Protect Patient Health Information

• Protect patient health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities

Clinical Decision Support

• Implement clinical decision support interventions relevant to specialty or high clinical priority
• Enable drug-drug and drug-allergy interactions

Computerized Provider Order Entry (CPOE)

• Medication orders created by the EP should be recorded using CPOE
• Lab orders created by the EP should be recorded using CPOE
• Radiology orders created by the EP should be recorded using CPOE

Electronic Prescribing

• Prescriptions written by the EP should be transmitted electronically using certified EHR technology

Health Information Exchange

• When transitioning a patient to another setting of care or referring the patient, providers should create a Summary of Care record and electronically transmit it using certified EHR technology

Patient Specific Education

• Provide patients with specific education resources that are identified by certified EHR technology

Medication Reconciliation

• Perform Medication Reconciliation for patients transitioned into the care of the EP

Patient Electronic Access (VDT)

• Provide patients with timely access to view online, download, and transmit their health information
• Health Information is viewed online, downloaded, or transmitted by patients

(The threshold for this objective has been reduced from 5% patients to 1 patient or more)

Secure Messaging

• Provide patients the capability to send and receive a secure electronic message with the EP

(The threshold for this objective has been reduced from 5% patients to functionality fully enabled)

Public Health Reporting

• Submit immunization data to an immunization registry
• Submit syndromic surveillance data to a public health agency

These new changes in Modified Meaningful Use Stage 2 will apply from 2015 to 2017, as shown in the table below:

Tips to Prepare for Meaningful Use Attestation

The sudden announcement of the new MU requirements and the short timeframe provided to physicians to prepare for them, has left them in panic. To help reduce the stress, CureMD shared a checklist of 6 things all practices must focus on completing within this timeframe.  Given below are some tips for you to follow, while completing this checklist:

 

1. Choose Your Reporting Period

• The Final Rule from CMS states that all providers will attest for a 90-day reporting period in 2015
• The stage or year you were in previously, is irrelevant

2. Perform A Security Risk Analysis

• Must be conducted at least once before attesting for MU
• Identify and correct security deficiencies
• Once done, you can attest to CMS that you have conducted this analysis
• A copy of the document must be maintained in case there is an MU audit

3. Read The Exclusions

• Out of the 10 objectives listed in the Final Rule, Stage 1 EP’s get an exclusion for 4 objectives as there was no equivalent core measure in Stage 1
• Stage 1 EP’s can pick an ‘Alternative Measure’ in 3 objectives to reduce the threshold required for reporting
• For Public Health Reporting, both Stage 1 and Stage 2 EP’s can meet only one measure
• EP’s scheduled for Stage 2 do not get any exclusion in the remaining objectives. This condition, however, does not apply to EP’s with a hardship exception

4. Contact Your Public Health Agency

Following two measures must be met for Public Health Reporting:

• Immunization Registry

Make sure you have an interface with your state registry. Contact your vendor in case you don’t.

• Syndromic Surveillance Reporting

Your EHR should be capable of extracting this report. Identify a Public Health Agency where you can submit this report.

5. Create Your Audit Folder

• Your audit folder must include the following documents:
  • KPI Screenshot
  • CQM Screenshots
  • Security Risk Analysis Document
  • Public Health Registration/ Enrollment Request Email
  • Medicaid Patient Volume Report (in case of Medicaid)
• Providers selected for both pre and post-payment audits will have to present supporting documentation to validate submitted attestation data
• EPs must keep their audit documentation with them for the next 6 years, post-attestation

6. Hardship Exceptions to Avoid Medicare Payment Adjustments

• Eligible professionals can apply for hardship exceptions in the following categories:
  • Infrastructure
  • New Eligible Professionals
  • Unforeseen Circumstances
  • Patient Interaction
  • Practice at Multiple Locations
  • PECOS Specialties

• To be considered for an exception, an eligible professional or eligible hospital must complete a hardship exception application along with proof of the hardship
• If approved, the hardship exception is valid for 1 payment year only. A new application must be submitted if the hardship continues for the following payment year

To view the complete webinar recording, click here.

Should you attest for Meaningful Use?

Even though the Final Rule was released close to the end of the year, CMS did not postpone the attestation deadline any further than the end of February 2016. If your practice has already completed the checklist shared above, then attesting for Meaningful Use will not be a hassle at all.

On the other hand, if your practice is not ready and chooses not to attest for Meaningful Use during this timeframe, your practice will be subject to the 2017 payment adjustment.

The final call is yours. Should your practice start preparing within this short timeframe to meet the new requirements released by CMS or would you rather take the penalty?

To get more information on the requirements for Meaningful Use attestation and how to meet them, contact our MU experts at 718-213-4870 or mu.consulting@curemd.com.